G.R. No. 210822 , June 28, 2021
FLORANTE VILLAROMAN AND CARLOS VILLAROMAN, PETITIONERS, VS. ESTATE OF JOSE ARCIAGA AND FELICIDAD FULGENCIO REPRESENTED BY THEIR HEIRS, ANICIA, DANILO, ROMEO, ORLANDO, MERCEDITA, EULALIA, ADRIANO, FERNANDO, AND EDGARDO, ALL SURNAMED ARCIAGA, RESPONDENTS.

FACTS

Petitioners Florante and Carlos Villaroman are heirs of Agrifina Cawili Vda. De Villaroman. Respondents are heirs of Jose Arciaga, a registered owner of Lot 965. On September 4, 1968, Jose sold a 300-square meter portion of Lot 965 to Ricardo Florentino via a Kasunduan ng Bilihan, with a down payment of P5,000 and a P1,000 balance payable upon transfer of title. Florentino paid the balance on January 8, 1969, but Jose failed to transfer the title. On January 12, 1971, Florentino sold the same portion to Agrifina. Agrifina built improvements on the land. Jose died on November 25, 1976. On April 2, 1980, a Kasulatan ng Bilihang Ganap for the absolute sale of Lot 965 was executed, purportedly signed by Jose (despite his 1976 death), Felicidad (Jose’s wife), and Alfredo Arciaga (Jose’s brother), in favor of Agrifina, Emilia Fresnedi, and Artemio Arciaga. Based on this, TCT No. 138549 was issued to Agrifina for the 300-square meter portion.
Respondents filed Civil Case No. 11993 for Annulment of Deed of Absolute Sale and Reconveyance against Agrifina, Emilia, and Artemio, claiming the 1980 deed was falsified. The RTC initially dismissed the complaint, but the CA, in a January 30, 1997 Decision, reversed the RTC, declared the 1980 deed void for being falsified (as Jose was already dead), and ordered reconveyance of the properties to Jose’s estate. The CA noted that the earlier Kasunduan ng Bilihan between Jose and Florentino did not transfer ownership but only a right to acquire ownership, and that the proper remedy for Agrifina was to file an action for specific performance against Jose’s heirs. This CA Decision became final on March 7, 2000.
Subsequently, petitioners filed Civil Case No. 00-113 for specific performance against respondents, praying that respondents execute a deed of absolute sale to formalize the transfer of the 300-square meter portion based on the 1968 Kasunduan ng Bilihan (Jose to Florentino) and the 1971 Kasulatang Tapos at Lubos na Bilihan (Florentino to Agrifina). The RTC ruled in favor of petitioners, ordering respondents to execute a deed of sale. The CA reversed the RTC, dismissing the complaint on grounds of res judicata and forum shopping. Petitioners elevated the case to the Supreme Court.

ISSUE

Whether the CA correctly dismissed the complaint for specific performance (Civil Case No. 00-113) on the grounds of res judicata and forum shopping.

RULING

Yes, the Supreme Court affirmed the CA’s dismissal. The elements of res judicata are present: (1) the prior judgment (the CA’s January 30, 1997 Decision in Civil Case No. 11993) is final; (2) it was rendered by a court of competent jurisdiction; (3) it is a judgment on the merits; and (4) there is identity of parties, subject matter, and causes of action between the prior and subsequent cases. The Court found identity of causes of action. In both cases, the core issue was the ownership and right to possess the 300-square meter portion of Lot 965. The relief sought in the first case (reconveyance) and the second (specific performance to execute a deed of sale) arose from the same set of facts or transactions involving the same property. The CA in the first case had already conclusively ruled that the 1980 deed was void and that the 1968 agreement only conferred a right to acquire ownership, suggesting the remedy of a separate action for specific performance. However, this suggestion did not preclude the application of res judicata, as the cause of action regarding ownership based on the series of transactions had already been adjudicated. The Court also found forum shopping, as petitioners filed the second case while raising the same claims and seeking essentially the same relief (affirmation of ownership over the property) that was already passed upon in the first case. The petition was denied.